KWC - Due Diligence, Directors' Report & Financial Statements

Summary

The requester sought due diligence records, financial statements, and correspondence regarding a £2.2 million grant to King William's College (KWC) from the Department for Enterprise. The authority responded by disclosing four emails containing KWC financial statements for 2022 and 2023, though the provided text cuts off before confirming the full scope of the due diligence or economic impact data requested.

Key Facts

• The request concerns a grant/loan of approximately £2.2 million awarded to King William's College.
• The Department for Enterprise disclosed financial statements for KWC and its subsidiary companies.
• The disclosed documents include statements for the years ending 2022 and 2023.
• The request specifically asked for due diligence conducted on KWC's funding approval.
• The response included four emails sent on 21 August 2024 containing the financial attachments.

Data Disclosed

• £2.2 million
• 2025-05-12
• 2026-03-06
• 21 August 2024
• 31 August 2020
• 31 August 2024
• 31 August 2023
• 440 Island pupils
• £2 million
• 12 pages
• 2 documents

Original Request

Further to FOI Request 4587906 submitted 14th April 2025 re the awarding of a grant/loan of c£2.2 million of taxpayer's money and the public availability of KWC Directors' Reports & Consolidated Financial Statements I seek the following additional specific information relating to successive KWC Directors' Reports and Consolidated Financial Statements: Such information relating to any financial and other due diligence conducted by the DfE (if any) on KWC and its subsidiary companies in relation to these reports/accounts and KWC's funding request and approval. This includes but is not limited to scrutiny of successive Company Directors' Reports & Consolidated Financial Statements and other accounts, monthly budget and cash flow analysis, Independent Auditor's Reports etc; and Details (confirmation (or otherwise) of holding, date of receipt and any correspondence requesting the copies of the same) of the KWC Directors' Reports & Consolidated Financial Statements and such other relevant (KWC) Company Accounts held by the DfE for the company's last five financial years ending 31 August 2020 to 31 August 2024 inclusive together with such other accounting documentation produced to date by KWC that is held; and Such information held which corroborates the assertion made in KWC Directors' Report & Consolidated Financial Statements for the year ended 31st August 2023 regarding the College's contribution to the local economy. This includes but is not limited to supply chain value and the claim that by educating circa 440 Island pupils they relieve the local Government of circa £2 million of education costs annually; and Correspondence both internal to the DfE and other areas of government, KWC auditors, The College and any other stakeholder relating to any matter reported in the Directors' Report and Consolidated Financial Statements and other KWC accounting documentation.

Data Tables (5)

Full Response Text

1 From: Sent: 21 August 2024 09:20 To: Subject: KWC Financial Statements - email 1 of 4 Attachments: KWC Financial Statements 2023.pdf Caution: This email is from an external sender. Please take care before opening any attachments or following any links.
Dear

Please find attached he first set of financial statements.

Kind regards

This e-mail and any attachment(s) is strictly confidential and intended solely for the addressee. Access to this e-mail by anyone other than the intended recipient is unauthorized. If you are not the intended recipient, you must not use, copy, distribute, disclose or rely on this e-mail or any part of its contents. If you have reason to believe that you are not the intended recipient of this communication please notify the sender immediately, delete it and destroy all copies. Computer virus can be transmitted by e-mail. The recipient should check e-mail and any attachment(s) for the presence of viruses. King William’s College & the Buchan School accept no liability for any damage caused by any virus transmitted by this e-mail. King William’s College & the Buchan School reserve the right to read any e-mail or attachment(s) entering or leaving its systems from any source without prior notice.
This document originates from the Department for Enterprise 1 From: Sent: 21 August 2024 09:22 To: Subject: RE: KWC Financial Statements - email 2 of 4 Attachments: King William's College and Subsidiary Companies 2022.pdf Caution: This email is from an external sender. Please take care before opening any attachments or following any links.
2nd set of financial statements.

From:

Sent: 21 August 2024 09:20 To:

Subject: KWC Financial Statements - email 1 of 4

Dear

Please find attached he first set of financial statements.

Kind regards

This e-mail and any attachment(s) is strictly confidential and intended solely for the addressee. Access to this e-mail by anyone other than the intended recipient is unauthorized. If you are not the intended recipient, you must not use, copy, distribute, disclose or rely on this e-mail or any part of its contents. If you have reason to believe that you are not the intended recipient of this communication please notify the sender immediately, delete it and destroy all copies. Computer virus can be transmitted by e-mail. The recipient should check e-mail and any attachment(s) for the presence of viruses. King William’s College & the Buchan School accept no liability for any damage caused by any virus transmitted by this e-mail. King William’s College & the Buchan School reserve the right to read any e-mail or attachment(s) entering or leaving its systems from any source without prior notice.
This document originates from the Department for Enterprise 1 From: Sent: 21 August 2024 09:23 To: Subject: RE: KWC Financial Statements - email 3 of 4 Attachments: King William's College and Subsidiary Companies.pdf Caution: This email is from an external sender. Please take care before opening any attachments or following any links.
3rd set of financial statements.

From:

Sent: 21 August 2024 09:22 To:

Subject: RE: KWC Financial Statements - email 2 of 4

2nd set of financial statements.

From:

Sent: 21 August 2024 09:20 To:

Subject: KWC Financial Statements - email 1 of 4

Dear

Please find attached he first set of financial statements.

Kind regards

This e-mail and any attachment(s) is strictly confidential and intended solely for the addressee. Access to this e-mail by anyone other than the intended recipient is unauthorized. If you are not the intended recipient, you must not use, copy, distribute, disclose or rely This document originates from the Department for Enterprise 2 on this e-mail or any part of its contents. If you have reason to believe that you are not the intended recipient of this communication please notify the sender immediately, delete it and destroy all copies. Computer virus can be transmitted by e-mail. The recipient should check e-mail and any attachment(s) for the presence of viruses. King William’s College & the Buchan School accept no liability for any damage caused by any virus transmitted by this e-mail. King William’s College & the Buchan School reserve the right to read any e-mail or attachment(s) entering or leaving its systems from any source without prior notice.
This document originates from the Department for Enterprise 1 From: Sent: 13 September 2024 18:36 To: Cc: Lewin, Mark (DFE); Stewart, Andrew; Subject: KWC Application for Financial Support Attachments: Document 1 DfE Trading Summary Commentary.pdf; Document 2 Company Structure 2021.pdf; Document 3 Narrative on Buisness Plan VAT Scenarios.pdf; Document 4 KWC 5 year plan - scenario 1.xlsx; Document 5 KWC 5 year plan - scenario 2.xlsx; Document 6 KWC 5 year plan - scenario 3.xlsx; Document 7 KWC 5 year plan - scenario 4.xlsx; Document 8 Facility Letter - £2,000K Loan June 2024.pdf; Document 9 Facility Letter - £750K Loan June 2024.pdf; Document 10 Facility Letter - Current Account June 2024.pdf; Document 11 KWC application-for-fas-v1 signed.pdf; Document 12 DfE FAS additional info.pdf; Document 13 Chairman's Letter to Parents 2 July 2024.pdf; Document 14 Principal's EOT Newsletter_28_06_24.pdf Caution: This email is from an external sender. Please take care before opening any attachments or following any links.
Dear ,

My apologies for taking a little time following our call to get the information requested but hopefully the undernoted and attached now goes some way to providing you with what you need.
It is a big pack and I hope it makes sense in the context of our discussion. Obviously if you wish to discuss any aspect of the information or have further queries, please do not hesitate to contact me.

INFORMATION REQUESTED 1. 3 years full financial accounts for the past 3 years – provided ahead of our call.
2. Narrative on the losses in the last couple of years – attached as document 1. 3. A company structure, showing all the charities and businesses, including what they do and any associated accounts. Please include all directors/any shareholders – attached as document 2. 4. The employing entity – we confirm this is King William’s College. There are no staff within any of the other entities in the company structure.
5. Confirmation which entity the cash flow is attributed to – we confirm this is King William’s College. The cash movements in the other companies are not significant to this application.
6. A 5 year cashflow forecast showing the College’s position should the fees be increased in line with the VAT applied – see documents 3 to 7. 7. A 5 year cashflow forecast showing the College’s position if fees were increased in order to deal with VAT charged at a rate of 5% - see documents 3 to 7. 8. Annual total number of staff and the average salary included in the cash flow – as discussed, you have this within the spreadsheet 5 year plans.
9. Any security that can be offered to the Department – to be discussed as a separate matter.
10. Details of the debt, including facility agreements – see documents 8 to 10.
This document originates from the Department for Enterprise 2 11. Application form – see document 11 and 12. 12. Any business plan for the next year or preferably onwards, included funding projects – as discussed, documents 13 and 14 support the numbers in the spreadsheet 5 year plan.
13. In addition to the above forecasts, the same forecasts but to include the sale of the Buchan Site, the incremental payments expected, the costs associated and the expected reclaimed VAT on such works – as discussed, we confirm this is already assumed within the 5 year business plans.

Kind regards

This e-mail and any attachment(s) is strictly confidential and intended solely for the addressee. Access to this e-mail by anyone other than the intended recipient is unauthorized. If you are not the intended recipient, you must not use, copy, distribute, disclose or rely on this e-mail or any part of its contents. If you have reason to believe that you are not the intended recipient of this communication please notify the sender immediately, delete it and destroy all copies. Computer virus can be transmitted by e-mail. The recipient should check e-mail and any attachment(s) for the presence of viruses. King William’s College & the Buchan School accept no liability for any damage caused by any virus transmitted by this e-mail. King William’s College & the Buchan School reserve the right to read any e-mail or attachment(s) entering or leaving its systems from any source without prior notice.
This document originates from the Department for Enterprise

Freedom of Information Co-ordinator 1st Floor, St Georges Court Upper Church Street, Douglas Isle of Man IM1 1EX

Telephone: (01624 686400) Website: https://www.iomdfenterprise.im/

Our ref: 4648817 9th March 2026

Dear

Re: Decision Notice 2026_02 – Isle of Man Information Commissioner

In accordance with the above stated decision notice, I have undertaken a reassessment of your Freedom of Information request, that was submitted to the Department on the 12th May, 2025.

Your request asked for the following information.

" Further to FOI Request 4587906 submitted 14th April 2025 re the awarding of a grant/loan of c£2.2 million of taxpayer's money and the public availability of KWC Directors' Reports & Consolidated Financial Statements I seek the following additional specific information relating to successive KWC Directors' Reports and Consolidated Financial Statements:

Such information relating to any financial and other due diligence conducted by the DfE (if any) on KWC and its subsidiary companies in relation to these reports/accounts and KWC's funding request and approval. This includes but is not limited to scrutiny of successive Company Directors' Reports & Consolidated Financial Statements and other accounts, monthly budget and cash flow analysis, Independent Auditor's Reports etc; and

Details (confirmation (or otherwise) of holding, date of receipt and any correspondence requesting the copies of the same) of the KWC Directors' Reports & Consolidated Financial Statements and such other relevant (KWC) Company Accounts held by the DfE for the company's last five financial years ending 31 August 2020 to 31 August 2024 inclusive together with such other accounting documentation produced to date by KWC that is held; and

Such information held which corroborates the assertion made in KWC Directors' Report & Consolidated Financial Statements for the year ended 31st August 2023 regarding the College's contribution to the local economy. This includes but is not limited to supply chain value and the claim that by educating circa 440 Island pupils they relieve the local Government of circa £2 million of education costs annually; and

Correspondence both internal to the DfE and other areas of government, KWC auditors, The College and any other stakeholder relating to any matter reported in the Directors' Report and Consolidated Financial Statements and other KWC accounting documentation. "

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Our response to your request is as follows:

Your request comprises of four elements, and I have addressed each in turn below.

Where information is already publicly available or has been released previously a link to the source is provided.

My interpretation of your request notes that the information seeks “specific information relating to successive KWC Directors’ Reports and Consolidated Financial Statements:”, accordingly, my response reviews your request in relation to the audited consolidated Financial Statements held by the Department at the time of the assessment of the financial support application. Your request has been broken down as follows:

1. Due Diligence on Financial Statements (signposted)
2. Confirmation of Financial Statements held (Appendix A)
3. Economic Impact Evidence (signposted), and
4. Correspondence (Appendix B)

Any personal data in the appendices, particularly names or email addresses, has been redacted as it is considered absolutely exempt information under Section 25 (2) a and b of the Act (personal information).

This exemption applies because:

• The Department is satisfied that the information amounts to personal data of which you are not the data subject; and • The Department is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Department can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met.

1. Due Diligence on Financial Statements

You asked for information relating to any financial and other due diligence conducted by the Department on KWC and its subsidiaries’ Financial Statements, including scrutiny of Directors’ Reports, consolidated financial statements, cashflow analysis, auditor reports and similar.

The assessment criteria for an application under the Financial Assistance Scheme (FAS, the ‘Scheme’) and factors relevant to an award of financial assistance are noted in the FAS Guidance (pre 1/4/25), with further specific assessment criteria detailed for applications under Appendix 5 (to which this application relates) shown below:

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A. Impact on the economy if the business were to cease trading: There can be significant adverse consequences if a business ceases to trade, for its employees, customers, creditors, the taxpayer and the wider economy. The applicant should provide relevant information to help to assess the possible impact.

B. Growth prospects: The Scheme is principally intended to aid the growth of the Island’s economy. The applicant should provide evidence of the prospects for future growth of the business and the potential to generate additional revenue, spending in the local economy, the effect on Government income, and job creation.

C. Sources of capital: A business experiencing financial difficulties typically requires additional capital to enable it to survive and thrive. In such a situation the Department would not expect to be the sole provider of finance and would anticipate that shareholders and /or third parties also provide finance to the business.

I kindly refer you to the response provided by Treasury in Freedom of Information request ID 4750173, specifically Appendix 1 of this respons

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